Fwd: Emailing: ingots-uranium follow up

ATTACHMENT A-3 J- ~anas230

From: .
To: Dan McKeel <
Subject: Fwd: Emailing: ingots-uranium follow up
Date: Tue, Jun 4, 2013 9:58 am

Begin forwarded message:

From: ~ " b
Date: April 22. 2009 11:15:03 AM CDT
To:

Cc: © >

Subject: Re: Emailing: ingots-uranium follow up

Dr. Dan--4/22/09 | talked with ~ . * this morning to clarify what he thought
was a billot. stated” it was about 10 feet long, circular, and flat on one side, and
the shipping tag said General Steel and underneath it said Granite City Army Depo. It
was unclear to me if this was a billot. | do confirm 's sightings of ingots, for | saw
them myself.

The ingots | saw were a solid cylinder, about 20 inches high and 18 inches or so
in diameter.The ingot, when shot, was stood on end and the upper left and upper right
corners were shot. The ingot was then inverted end for end, and rotated 180 degrees,
and the other two corners shot. The 14 x 17 metal film cassette was set vertically.
With extension of the film on the side and top to create a black edge. This allowed

-enough room to flatten a curved surface on a flat film and show the "black" edge. The
film would be set to expose the first one inch to inch and one half of metal. In reading
the film, left to right, you would see a black edge, lighter metal, and then increasing
lighting on the film as depth and density increased towards the center of the core. In
short, desirability would be to read the first inch to inch and one half of metal depth. If

the ingots were numbered it was Usually painted on the ingot and the lead number
taped on a readable portion of the film cassette. The shots were of no unusually long
duration and were treated as shooting 3 to 3 and one haif inches of steel.
. )
24 & 25 MEV Betatron & Magnaflux Operator
General Steel Industries

—----Original Message-——-

From: DanMckKeel
Date: 4/22/2009 5:06:36 AM
To: a ee —

Ce: DanMcKeel, oo
Subject: Re: Emailing: ingots-uranium follow up

and

Thanks to _ for the write up and for forwarding it and having the meeting. Attached is a

‘http://mail.aol.com/37752-111/aol-6/en-us/mail/PrintMessage.aspx Page 1 of 3


McKeel review of Alien GSI dose summary Aug. 2013

research, calibration of various instruments, and teaching. Recently it was calibrated using ion
chambers. The source and room were also modeled in Monte Carlo N-Particle transport code
(MCNP%5) to determine if the use of a new feature called mesh tallies produces a dose map in
the entire room that agrees with the measured results. The dose rate in the hallway, while the
source is exposed, was also calculated. It was found that the dose rates calculated from the
MCNPS5 are in reasonable agreement with the measured results and theoretical
predictions. It was also confirmed that the dose rates where the user often stays during the
measurement are well below the annual limits. This project shows that the MCNP5 mesh tallies
are useful tool for dose mapping in many operational radiation protection situations.

PMID: 15654243 [PubMed - indexed for MEDLINE]
Table 1 from this article, column 5, shows that at multiple locations experimental (measured)
data agrees with MCNP5 data within 2.19 to 5.32%.

Table 1. Comparison of MCNP calculations and measured data. The
statistical errors from the MCNP5 codc are less than 2% for the locations on
the calibration bench. The measured results here were interpolated from
the ion chamber readings using Microsoft Excel (Microsoft Corporation, One
Microsoft Way, Redmond, WA 98052).

Statistical Measured Difference between
Distance MCNP results Uncertainty in results MCNP and measured
(cm) (Gy h°) MCNP (%) (Gy hv!) results (%)
0 203.1404 0,001
20 0.1323 0.193
40 0.0332 0.387
60 0.0147 0.581 0,0152 2.70
80 0.0083 0.773 0.0085 2.19
100 6.0053 0.968. 0.0055 2.49
120 0.0037 1.168 0.0038 3.48
140 0.0027 1.359 0.0028 2.87
160 0.0020 1.563 0,0021 4,23
180 0.0016 1.766 0.0017 5.20
200 0.0013 1.959 0.0014 5.32

4. Juste B, Miro R, Morera D, Diez S, Campayo JM, Verdu G.

The Institute for ( Industrial, Radiophysical and Environmental Safety (ISIRYM),
Polytechnic University of Valencia. Valencia, Spain. bejusvi@ign.upv.es MCNP5 Monte
Carlo simulation of amorphous silicon EPID dosimetry from MLC radiation therapy
treatment beams. Conf Proc IEEE Eng Med Biol Soc, 2012;2012:5786-9. doi:
10.11091EMBC.2012.6347309

Abstract

The present work is focused on a MCNP Monte Carlo (MC) simulation of a multi-leaf
collimator (MLC) radiation therapy treatment unit including its corresponding Electronic
Portal Imaging Device (EPID). We have developed a methodology to perform a spatial
calibration of the EPID signal to obtain dose distribution using MC simulations. This
calibration is based on several images acquisition and simulation considering different

~13-


McKeel review of Allen GSI dose summary Aug. 2013

Table 1 — intake Estimate

Start Date End Date Uranium inhalation | Inhalation Total Ingestion
work from from inhalation (dpm/day)}
(hr/yr} handling rasuspension | {dpm/day)
(dpm/day) | {dpm/day)

10/1/1952 | 6/30/1961 337.5 76.99 14.41 91.40 15.45
7/1/1981 | 6/30/1962 437.5 99.80 14.41 114,22 15.45
7/1/1962 | 6/30/1963 125 28.52 14.41 42.93 15.45
7/1/1963 6/30/1965 28 6.39 14.41 20.80 15.45
7/1/1965 6/30/1966 13 2.97 14.41 17.38 15.45

Page 3 of
After 144 1.44 15.45
6/30/1966

Note: the values after 6/30/1966 are reduced using depletion factor fram ORUAT-OTIB-0070.

[16] Regarding the footnote to Table 1, page 3: [McKeel 16] The use of TIB-70 as
being appropriate for GSI was strongly challenged by McKeel as GSI SEC-00105 co-
petitioner in a white paper delivered to the TBD-6000 WG and full Board on 6/19/13.

Summary of External Dose Estimates

Below is the summary of the external dose estimates currently proposed to be used in revising Appendix
BB. Most but not all have been discussed previously in work group meetings. Disagreement still exists
for some and others have not been discussed. [McKeel 17

{17] This statement in two sentences needs to be documented by specific
citations of dose data Mr. Allen considers (a) established and agreed to by all (including
the petitioners), (b) issues where known disagreement exists (including the petitioners),
and (c) data that had never been discussed. That Mr. Allen avoids this necessary and
obvious task severely weakens the impact of this paper. He especially needs to identify
and scientifically justify new dose calculations NIOSH has made subsequent to the
6/20/13 TBD-6000 WG meeting. Avoiding that task is scientifically unacceptable.

First, a dose estimate for administrative personnel was derived in a NIOSH white paper issued in May
2013. [McKeel 18] The estimate was based on radium radiography in the areas of the plant outside the
radiography room. [McKeel 19] No discussion was held about a dose estimate following the end of
radium radiography in 1963. [McKeel 20] This white paper proposes to continue using that estimate to
the end of the covered period. It is intended that this be favorable since dose estimates for radiographers
persistently indicated higher exposures during radium radiography than during cobalt radiography and the
trend should also apply to administrative personnel. [McKeel 21]

{18] “A dose estimate” is too brief and vague. Were doses for photons, neutrons
and beta and intakes (inhalation and ingestion) for all GSI radiation sources in

-4-


aolrich://278147510°

ATTACHMENT B

Historical data details reply
Monday, February 5, 2007 5:13:36 PM
DanMcKeel2

My sincere thanks for these excellent data. Rarely these days do | get such clear and straightforward
answers. The workers are indebted to you. We will probably request some detailed weekly reports on
perhaps up to 4 or 5 of the individuals with film badge data. We need to find out more details about what
the men with the highest readings did. It looks like they worked with isotopes, probably the cobalt-60
and iridium-192 sources and did overtime work as Betatron operators.

| will make sure you get paid promptly for your research and copying expenses. Thank you again for the
really great way you handled this request to resurrect the past in order to help some people living

today.
-- Dan McKeel 2/5/07

In a message dated 2/5/07 4:37:29 PM,

=| Hello Dan, .
When we spoke last, you asked me to find the minimum reporting level and radiation exposure limits for the badges that
were reported in 1963-1973 for account 2084. I have found this information, with help from ~ Here is

what we found.

For the years 1963-1970, the minimum reporting levels are as follows:
Xray or gamma: 10mrem

Hard beta: 40mrem.

Fast neutron: 15mrem

Thermal neutron: 10mrem

In 1970, the Fast neutron minimum changed to 20mrem and all other levels remained the same, despite changes in badge
types. This information was procured from archived Landauer reports.

As far as permissable doses, this is what we found:

Starting in 1958, the dose limit regulations began using the concept of a dose limit beyond one year. In other words, the
average dose over a period of years should not exceed an average of 5 rem per year.

The dose limit specified is 3.0rem/13 weeks. The annual limit is 5(N-18)rem when N=participants age. This information
is from the Addendum to the NBS handbook #59.

The regulation stated above was in place from 1958 until 1988 when the DOE changed the limit to Srem/year.

This information was confirmed on a few different websites:
http//www.nmeco.com/education/facts/history/standards.htm

http://www.hps.org

www.ieer.org

Please let me know if you have any other questions.
Thanks,



7117/13 10:29 AM

ATTACHMENT A-2 f-

12.. If the trucks were moved into the betatron, then each one would be handled indivually with the
overhead crane and chain and a choker. if they were unloaded into the betatron, a fork truck would move
each pallet and place them in the shooting area. Don't know. Never saw it happen.

13.Don't nave any idea.

14. I think on wooden palettes.

15. Don't know

16. Don't know, se '

17. Don't know. We had two methods of marking the metal castings. One was with a metal stamp
which looked like a 6" cold chisel with a number on one end. It was placed on the metal and hit with
about a five lb sledge to leave a nember indent on the metal.. The second method was with a paint tube.
This looked like a tube of toothpaste with a boll on the end which when depressed would allow yellow
paint to come out of the tube andyou could write on the metal surface.

18. They would have to be unloaded, chained and set up on sew horses, a cassette with film loaded
would then be placed or positioned behind the Ingot. 1 understand the cassette was propped up on
wooden blocks to get the right position. Lead number and/or letters were placed on the cassette which
would allow the allow the position and the number of the shot to be superimposed on the film. Then a
corresponding number would be stamped or printed on the ingot.. Then the film and the camera was lined
up at the correct angle and distance. When all was ready, the shot would take place.

19. The first positioning would probably take about one hour. Each subsequent set-up would take about
15 minutes. Chaining and flipping the ingot would probably add another 15 minutes to the operation.
Therefore one hour 15 mins. to get the 1st two shots, 45 minutes to flip and get the next two shots
and about 15 minutes to chain and return the ingot to the pallet or the truck.

20:lam altiost positive that each shot took 40 minutes.

21. Remember several names. all of whom are
deceased and: — .

22. Again, | never personally shot or was even present when and ingot was processed.

Sorry, this is the best that | can do. SO years is a long time for me to remember anything.

Daniel W. McKeel, Jr., MD

sout:blank Page 2 of 3


MeKeel review of Allen GSI dose summary Aug. 2013

b) Triangular distribution agreed to in a Work Group meeting on 2/21/2013. The maximum of
the distribution was to be the dase limit. The mode was the SC&A estimate contained in
“Update on the Use of Sealed Radioactive Sources at General Steel Industries” issued
October 2011. The minimum was the NIOSH estimate from “Battelle-TBD-6000 Appendix BB
General Steel Industries Dose Estimates for Portable Radiography sources” issued August
2011 and adjusted to 1 radiographer instead of two.

c) Values for 1964 — 6/1966 are for Layout man from NIOSH “Addendum to Dose Estimates for
Betatron Operators White Paper” issued March 2012.

d) Non-penetrating dose values adjusted based on new activation calculation using MCNPX
2.7.

[30a] The legend to Table 3 requires further commentary.
TABLE 3 legends:

+ Footnote (a) There are several “official” radiation dose limits, including a letter
from at Landauer to Dan McKeel dated 2/5/2007 [ATTACHMENT B]. Mr. Allen
needs to justify why these NBS 59 data 4/15/1958 are determinative. NYO-4699 (Suppl. 1)
1957 REF1 also has information about prevailing maximum permissible dose limits HASL
NYO was using in its Accelerator Survey Program during the 1950s. Mr. Allen should
identify the exact pages on which the relevant dose limits he proposes are presented
within NBS 59 to avoid citation ambiguity.

+ Footnote (b) The page(s) from the 2/21/13 TBD-6000 WG transcript and the two
August and October 2011 white papers that Allen refers to need to be stated here.

+ Footnote (c) “Layout man” as a concept about a discrete job category at GSI was
discredited by additional worker testimony and examination of a GSI union jobs list of
163 discrete jobs that was presented to NIOSH. No one was an exclusive Layout worker.

+ Footnote (d) Mr. Allen needs to provide the full methodology NIOSH used to
make “adjustments” and “new activation calculations using MCNPX 2.7.” He needs to
give details of the new assumptions and parameters used for these calculations. What
person actually performed the new activation calculations? We have previously strongly
objected to NIOSH using a single Fe59 isotope as the sole Betatron activation product,
citing papers by Guo and Ziemer and Kuttemperoor and others proving that high Mev
Linacs and Betatrons induced activation in a far larger range of isotopes emanating from
the Betatron internal components and the externa! metallic targets. This simplistic
approach of modeling activation at GSI is claimant unfavorable and scientifically
indefensible. Betatron activation of metal castings produced many radionuclides with
half lives longer than iron. We have documented these facts repeatedly and had them
ignored by NIOSH, the TBD-6000 WG and SC&A, and the full Board in its 12/11/12 final
9 to 8 vote to deny a GSI for 1953-1992. The covered period segments of 10/1/52-12/31/52
and extension of the residual contamination period into 1993 have not been considered.


McKee! review of Allen GSI dose summary Aug. 2013

one week-long stolen Ra-226 overexposure incident (§83.9) in October 1953, reported in
three newspapers, that needs to be factored into the equation and for which NIOSH and
SC&A have not calculated a gamma dose. SC&A has admitted and apologized to workers
for dismissing this incident as occurring at another location or not having occurred at all.

For reasons stated above, the zeros in columns 3, 4 and 5 of Table 2 need to be
changed to reflect the other GSI source terms noted above. It is incorrect and not
scientifically defensible to project gamma photon doses from Ra-226 only during 1952-
1962 to the last years of the covered period (1963-66) when Co-60 was used in addition to
uranium, Old and New Betatrons, 2 x-ray sources from GSI, Ir-192 sources and, St. Louis
Testing and American Steel, and two Co-60 small sources and possibly an 80 Ci Co-60
source 1964-66 as testified to by at least 6 GSI radiographers.*>  ~ of StLT Labs
testified recently the SLTL Ir-192 source was used at GSI 25 to 50 times from 1963-66,
while the StLT Labs 80 Ci Co-60 source was used only once, outside bidg. 10, for 1 week
and 1-day for a huge steel casting. Mr. . ‘has documented those SLTL sources.

Mr. Allen needs to document (prove) that Ra-226 gamma doses were higher than
(that is, were more bounding) compared to Co-60 gamma doses + Ir-192 gamma doses in
column 2 of Table 2.

Allen Page 4 of 6

Next, the doses for the remainder of the plant personnel are summarized. The dose estimates are divided
into three time frames. The first being the start of the GSI operational period until a change to the dose
limits found in NBS handbook 59 (October 1952 — 1958). The second period is from then to the end of
the radium radiography (1959-1963). [McKeel 24] The third is from the end of the radium radiography
until the end of the operational period at GSI (1964-1966).

[24] Mr. Allen neglects to state he is referring to TABLE 3, PAGE 4 in the ensuing
narrative. A dose cannot/should not be assigned for the 1952 extended covered period
until the different operational conditions prevailing at that time are acknowledged and
discussed by NIOSH as part of TBD-6000 WG deliberations. That has not yet happened.

First, the uranium source term for this 1952 period has not been defined by any
means; AEC/MCW purchase orders have.not been discovered for 1952-1958. NIOSH has
never discussed on the record the reports it submitted to DOL for October 1952, or that
were addressed in Dan McKeel’s white paper on the subject from November-December
1952 FOIA he submitted, that led DOL to alter and extend the GSI covered period start
date from 1/1/53 to 10/1/52. DOE FOIA records submitted by Dan McKeel show that, in the
last quarter of 1952, GSI performed R&D Betatron work for the AEC using Mallinckrodt
uranium sectioned billets in conjunction with a new uranium shield to improve NDT
radiographic image quality. This was a different NDT radiography mission than GSI
subsequently pursued in its AEC MCW purchase order contract 1958-1966.

Second, Mr. Allen needs to cite the relevant pages in NBS 59 he alludes to.

Third, Allen neglects mentioning that neither film badge nor AEC MCW purchase
orders nor any other source monitoring records for uranium exist from 1953 up through
part of 1958.

Fourth, separate external/internal doses at GSI have not been calculated by NIOSH
or SC&A for 1958-1963. SC&A relies entirely on a single summary 18 quarter film badge
report from GSI part-time radiographer and a letter from GSI
management to bound external doses during this period. Mr. Allen omits the important
information, as has SC&A in the past, that (a) this same film badge summary report also
includes a dose of 7.2 REM incurred for 2 quarters (6 months), while the GS! part time

-6-


McKeel review of Allen GSI dose summary Aug. 2013

compliance with OCAS-IG-0037? For what period of time were doses estimated? What
pages, figures and/or tables contain these data in the May 2013 white paper?

[19] The former “radium era” and this dose estimate neglect he fact that other
radiation sources were in use 1952-1962, besides Ra-226, which administrative personnel
could have been exposed to incur both neutron and beta doses. Namely, OCAS-IG-003
stipulates that all sources must be used in DR: at GSI this included the Old Betatron (24
MEV), two 250 Kvp x-ray units, an Ir-192 source, all of which could have delivered dose to
administrative personnet. NIOSH and SC&A have neglected these doses of neutrons,
x-ray scatter and beta dose from administrative personnel in the Betatron facility. NYO-
4699(Suppl. 1) 1957 demonstrates that ancillary personnel, nurses across a courtyard to
be specific, were exposed to betatron neutrons at U. IL medical school in the 1950s from
their 22.5 Mev Betatron.

{20] NIOSH admits but doesn’t address why this omission occurred or why they
cannot and have not calculated an intake dose for 1963-66 to the end of the covered
period. This should have been easily accomplished given that radiographer film badge
data was available for these 3 years.

[21] This analysis omits the fact that Betatron neutrons and beta dose were also
delivered to administrative personnel in addition to Ra-226 1952-1962 and cobalt-60 1963-
66 gamma dose. Again, no dose has been discussed for the last quarter of 1952 when
both Ra-226 and the Old Betatron plus two 250 Kvp x-ray and an Ir-192 source were in
use for GS! NDT radiography.

It should also be noted that with the source of gamma exposure being sealed radium sources, no neutron
or non-penetrating dose is produced and those dose estimates are zero [McKeel 22] The dose estimates
are listed in Table 2 below.

[22] “...the source of gamma exposure being sealed radium sources...” is an
incorrect statement. There were Ir-192 gamma photons, Betatron neutrons and beta skin
dose and x-ray photons, uranium photons and alpha, and x-ray photons from two
portable 250 Kvp x-ray sources delivered to administrative personnel as well as radium
gamma photons.

Table 2 - External Dose Estimate for Administrative Personnel

Gamma Neutron Non-Penetrating Non-penetrating
Hands and Forearms _| whole body
10/1952 - 1963 571.5 mefyr 0 0 0
1964 — 6/1966 571.5 mr/yr eI Lj ij 0

Notes:
a. From NIOSH White Paper “GSI - Dose Estimate from Radium Radiography to Employees not
Routinely Working in Production Areas”, May 2013.
b. Post radium era estimate continues radium era estimate as favorable based on radium era
estimates for radiographers being bounding.
[McKeel 23] The “radium era” was not uniform with respect to exposures during
1952-1962. No calculations have been made for 1952. The 6 building radiography room

was not built until 1955, and Ra-226 was testified to have been stored in 5 building ina
storage room when not being used for NDT work. There was also a well documented

-5-


ATTACHMENT A-3'a April 17, 2009

On Wednesday, April 15, 2009, : . . :
Had a discussion about Uranium Ingots , Dingots, and Billots at General Steel Industries. © * was a

railyard worker, and at one time, Assistant Yardmaster at GSI. ~~ had many years and Extensive
experience at GSI, and was actually the last person to leave the property at shutdown. Stated, “I

definitely saw billots and ingots brought in mostly by rail, and some brought in by truck. They were brought in ,
usually on midnight shift or on the weekends.” The ingots and billots were of “ROUGH?” finish, or surface.”

Of the ingots that: and ‘saw in the Betatrons, were all of a ““rough”- “crusty”,
Surface and not at all anything resembling a “finished “ surface.

The ingots were brought in to the Betatrons to have glancing corner shots taken of a shallow depth. AS
recalled by ~ The film was a 14 x 17 Metal Cassette extending outward on the side and top of the _
cylinder to catch the flattened curvature as it was blown on the film. The glancing corner shots were
remembered to be of short duration for shallow penetration of the ingot corner surface. When the top two corner
shots were completed, the ingot was flipped. End to end and rotated 180 degrees, and then the last two, just
inverted and rotated quadrant was shot. The ingot was inverted by using the betatron house crane.

- was considered management and a FILM READER at GSI and John Dutko was a
Betatron OPERATOR and Magnaflux operator. : stated that the INGOT FILM was only routinely
developed and checked at GSI and NOT READ---The film was then boxed and sent out.



McKee! review of Allen GSI dose summary Aug. 2013

operator estimate could be favorable to some. [McKeel 29] Therefore the betatron operator estimate is
included as Table 4 for comparison. [McKeel 30a,b

[27] Mr. Allen should cite the page numbers in the 2/21/13 TBD-6000 WG
transcript.

[28] | assume the foregoing paragraph refers to Table 4 (External Dose Estimate
fro Betatron Operators) and its legend on pages 5 and 6. This sentence should read
«,..the gamma dose estimate for the two Ra-226 sources... The sentence as written falsely
implies the radium source(s) were the sole (only) GSI radiation sources during 1952-
1962. As amply documented herein, Mr. Allen and NIOSH glibly ignore the many radiation
sources at GSI (uranium, Ir-192, Co-60, 250 KVP x-ray) as well as previous dose
estimates in Appendix BB Rev 0, which is totally ignored in this white paper, and dose
estimates for Betatrons modeled at first using Attila code by NIOSH and later by MCNPX
versions 25 through 27 code by SC&A. Allen ignores the much higher dose estimates for
Betatron operators for both NIOSH and SC&A in the 2008 time frame. Mr. Allen fails to
explain that NIOSH manipulated (“adjusted”) MCNPx photon dosimetry downwards using
‘film badge normalization,’ a process SC&A disapproved of using, in the absence of
validating measured Betatron doses, to conform with film badge data on a subset of GSI
radiographers 1963-66. The GSI petitioners have vigorously argued all along the RS
Landauer 1963-66 film badge data on 89 people was not representative of the entire 13
year covered period, or even of radiographers in general, or certainly of the 97% of the
GSI work force who were never badged but obviously should have been. The film badge

_data from Landauer applied to only 3 of 13 years during the GSI covered period.

[29] We object to the vague phrase “radium radiography dose estimate could be
favorable to most workers but the betatron operator estimate could be favorable to
some...”.used by Mr. Allen on several grounds. He needs to spell out in detail and justify
this rationale. Which specific workers fall into each “favorable” group? Certainly the high
Betatron-related neutron doses should be favorable to all GSI workers including
administrative personnel and anyone walking near the Betatron buildings. We have
proven previously the outdoor space between the two Betatron buildings at GS! was
heavily trafficked by a main road, numerous railroad tracks and related personne!
including yard men and crane operators. Many vehicles were parked in that area.

Table 3 ~ External Dose Estimate for Operational Personnel (non-administrative personnel)

Gamma Neutron Non-penétrating | Non-penetrating
(rem/yr) (rem/yr) hand and forearm | whole body
{rad/yr) (rad/yr)
10/1952-1958 * Tri 15/9.69/6.279 "| 0 0 o
1959 ~ 1963 Tri 12/9.69/6.279 ** | 0 0 0
1964-1966 | 4.483 © 0.148 ©) 2.658 FHI 1.462 34)

Notes:
a) Dose limit changed from 0.3 rem/week (15 R/yr} to 3 rem/quarter (12 rem/yr) in Addendum
to NBS 59 published 4/15/1958.

Allen Page 5 of 6



Dragon, Karen E. (CDC/NIOSH/EID)

From: DanMcKee!l

Sent: Friday, August 30, 2013 8:44 AM

To: pl.ziemer@comcast.net; Ziemer, Paul (CDC/NIOSH/OD); Katz, Ted (CDC/NIOSH/OD);
NIOSH Docket Office (CDC); wimunn@aol.com; josiebeach@ © * * j-poston@tamu.edu

Ce: danmckeel2@aol.com; —_

Subject: McKeel critique of Allen DCAS August 2013 wnite paper

Attachments: McKeel_AllenGSIdose_8.30.13.pdf

Paul Ziemer, Chair, and the TBD-6000 work group
Members of the full Board

Ted Katz, ABRWH DFO

NIOSH Docket 140 officer

August 30, 2013

Attachment <McKeel_AllenGS!dose_8.30.13.pdf> 3.4MB
Dear Dr. Ziemer, members of the full Board, Ted Katz and the NIOSH Docket 140 office,

lam hereby submitting a critical review of Dave Allen and DCAS' latest white paper dated August 2013, titled "Summary
of Dose Estimates for GSI." | suggested this paper be created at the 6/20/13 TBD-6000 WG meeting.

Ted Katz, please distribute this paper to the entire ABRWH and TBD-6000 WG members as appropriate. Thank you.

NIOSH Docket 140 (GSI) office, please consider this as submission to GS! Docket 140 and listing as a Discussion paper
under the next scheduled TBD-6000 work group meeting (probably September 2013). The title should be: Daniel W.
McKeel, Jr., M.D., "Critique of Dave Allen DCAS August 2013 white paper ‘Summary Dose Estimates for GSI.’ " Thank
you for your consideration.

| would like to reiterate my request when | submitted my white paper on NYO-4699 that SC&A be tasked to review it!
now add a request that SC&A also review the present paper which finds numerous factual errors and omissions in the
Allen August 2013 white paper. | appreciate your consideration of this further request.

The Allen paper will serve as the basis for Appendix BB, revision 1. | find this paper is flawed as was the original Rev 0 of
Appendix BB (June 2007) that omitted neutron dose, for example, yet nevertheless has been used for all GSI completed
DR to date except 4 DRs that are the subject of PER-24. | urge the Board to allow SC&A to please review my input before
Appendix BB‘Rev 1 is finalized.

Sincerely,
-- Daw McKeel 8/30/13 Friday
Daniel W. McKeel, Jr., MD

Cofounder SINEW
GSI SEC-00105 co-petitioner


McKeel review of Allen GSI dose summary Aug. 2013

[31] Use of Table 3 as it now stands would be distinctly unfavorable for anyone in
the 10/1952-1963 period because neutrons, non-penetrating hand and forearm doses, and
Non-penetrating whole body doses are listed as “0” (zero) values. As explained
previously, measured neutron data in NYO-4699 (Suppl.1) 1957 from similar Betatrons to
those used at GS! shows that neutron dose is a significant fraction of Maximum
Permissible Dose and in some instances (i.e. some locations) equals or exceeds the
maximum permissible dose.

Use of Table 4 is highly unfavorable to all Betatron operator radiographers for
multiple reasons:

(a) Assigned photon doses in column 2 are way below 2008 SC&A and NIOSH
levels. Do both agencies feel their 2008 computer models were grossly inaccurate?
SC&A used MCNPX from the beginning based on documented research that began in
2006 at the Fernald site (personal e-mail communication from John Mauro to © ~

ce: to Dan McKeel). NIOSH used Attila at first and switched to and adopted the
SC&A model. These important data have been suppressed by NIOSH-SC&A from the time
the NIOSH Path Forward for GSI Dave Allen initiative was first introduced and embraced.
This deliberate suppression and avoidance of historical data is scientifically dishonest.
(b) Table 4 data must, in the GSI co-petitioner’s opinion, be reconciled with the highly
relevant measured Betatron photon and neutron data and film badge data contained in
NYO-4699(suppl.1) 1957 [REF 1]. The neutron doses will definitely be higher [REF 1].

NIOSH and SC&A both need to review REF 1 (NYO-4699[Suppl.1] 1957) and report
back to the TBD-6000 WG and ful! Board. Dan McKeel requested the Board to do so when
he submitted the NYO-4699 white paper on 8/9/13; thus far there has been no response
by the WG or by NIOSH/DCAS to this very reasonable and appropriate McKeel request.

McKeel Comments in Conclusion

(a) NIOSH and SC&A need to incorporate AEC HASL report NYO-4699(Suppl.1) 1957 [REF 1]
measured Betatron photon and neutron and film badge data in order to validate their GS!
Betatron models that are not now so validated.

(b) McKeel REFS 3 nd 4 offer added proof of his contention that MCNPX models of various
radiation dosimetry situations agree to within 2 to 5% with “empirical measured” data. The
Board should hold NIOSH and SC&A to similar standards. They shared input files and the best
case agreement was 2-fold (200%), which does not meet modern professional standards.

(c) This paper omits a review of Appendix BB Rev 0 and NIOSH and SC&A external/internal
dosimetry values. This is a major omission since the purpose of this paper is to highlight
proposed changes since June 2007 that have been made for Rev 1 of the same guidance.

(d) The paper states that some new values have been introduced but doesn’t say exactly what

those changes are. This is another major omission. The new data needs to be flagged as such
explicitly and thoroughly discussed. DCAS was NOT tasked to create new GSI data.

(e) Specific pages in specific white papers and meeting transcripts are alluded to but not listed.
This makes verifying the citations for accuracy very difficult. In general, scientific references by
primary authors should be as exact and complete as possible.

-ll-


McKeel review of Alien GSI dose summary Aug. 2013

Table 4 — External Dose Estimate for Betatron Operators

Year Photon * Neutron & Non-penetrating Non-penetrating
rem/ys) rem/yr) Hands and forearms | whole bod
¥! ay
(radfyr)** (rad/yr)*!
| 10/1952-1960 0.590 0.050 26.904 2.755
1961 0.620 0,056 30.496 2.946
1962 0.557 0,043 22.863 2.539
1963 0.435 0.019 8.154 L755
1964 0.406 0.013 4.669 1.569
1965 0.401 0.012 4.130 1541
1/1966 -6/1966 | 0,199 0.006 1.796 0.756
Note:

a} Photon and non-penetrating values in this table come from the NIOSH white paper “Dose
Estimates far Betatron Operations” January 2012.

6] Neutron values in this table come from the NIOSH white paper “Addendum to Dase Estimates
for Betatron Operations” March 2012,

[30b} continued:

TABLE 4 legends:

* Footnote (a) Mr. Allen should cite the exact pages from the January 2012 white
paper. As stated many times in this paper and elsewhere, petitioners believe the
assigned photon doses based on MCNPX adjusted and normalized to the limited and not
representative GSI film badge data set should not have been used and are inaccurate.
These photon doses need to be assessed relative to measured Betatron photon doses in
REF 1 (NYO-4699[SupplI.1] 1957.

* Footnote (b) Mr. Allen should cite the exact pages from the March 2012 white
paper. As stated many times in this paper and elsewhere, petitioners believe the
assigned neutron doses based on MCNPX should not have been used and are inaccurate
(far too low). These MCNPX calculated (modeled) doses need to be assessed relative to
measured (real) Betatron neutron doses in REF 1 (NYO-4699[Suppl.1]) 1957.

Allen Page 6 of 6

With the exception of the hand and forearm dose, the total dose in Table 3 is always higher than the doses
in the betatron operator table (Table 4). For hands and forearms, the betatron operator total dose is higher
many of the years. Therefore, the recommendation in this white paper is to use Table 3 values for claims
(including betatron operators) but to use the more favorable values of Table 4 for skin dose of the hands
or forearms. [McKeel 31}

-10-


McKee! review of Allen GSI dose summary Aug. 2013

radiographer worked for Pittsburgh Testing doing Ir-192 NDT work (personal phone call
communication to and Daniel W. McKeel from during 2013; and
(b) the film badge summary report is not from RS Landauer Company who supplied all of
the GSI program #2084 film badges. The report format is completely different and one
sheet contains Nuclear Consultants Corp. as the source. Two FOIA requests to DOE and
NRC have failed (1) to establish NCC as a legitimate corporate entity or to reveal a source
term license even though a discrete AEC license number was quoted in McKeel’s NRC
FOIA 2010-0012 documents. Therefore, McKeel and - . assert the summary badge
report emanated from GSI rather than from Landauer and thus that film badge data
pedigree cannot be relied upon. "is unable to this day to explain the exact source of
his film badge data. He acknowledges never seeing any RS Landauer film badge reports.

In the third time period, the dose is based on the estimate for the layout man, which includes a gamma,
neutron and beta dose component. (McKeel 25] The beta dose estimate was based on activation of steel
by the betatron. It was pointed out previously that activation rates derived from MCNPX would change in
later versions of MCNPX. The values were recalculated using MCNPX 2.7 and the new values entered
into the same calculations performed previously to obtain a new non-penetrating dose estimates. [McKeel

26)

[25] “Layout man” is not a formal job description that existed at GSI. No person
we know of worked exclusiely as a layout person full time.

It is utter scientific neglect not to recognize that during 1952-1962, the entire
“radium era” at GSI, the Old Betatron, a 24 Mev Allis-Chalmers model with its own
standalone concrete and sand-filled thick walls and tin roof building, was in operation
processing AEC MCW uranium for NDT purposes., During 1963 through mid-1966 GSI
used both the Old Betatron and the New Betatron, which was moved from Eddystone PA
GSI Division when it closed in 1963 to Granite City GSI, where a New Betatron facility was
built attached by a short walkway to GSI building 10.

Dan McKeel’s August 2013 white paper on the HASL, NYO-4699(Suppl. 1) 1957
report gave measured high MEV Betatron photon and neutron data and film badge data
at three facilities (two at U. IL and a third at Memorial Cancer hospital in NY). in a similar
way, the GSI Old Betatron accelerator operating in x-ray mode gave significant beta dose
and, especially, neutron dose as well as photon doses that must be calculated by NIOSH
to replace the scientifically inaccurate “zeros’ in columns 3, 4 and 5 rows 2 and 3 of
Table 3 on page 4. Note that in 2008 NIOSH, and especially SC&A calculations, Betatron
operators received far higher doses compared to other GSI personnel, as is reflected in
June 2007 Appendix BB Rev 0 data that has been used as primary guidance at GSI for all
but 4 DRs that are covered by PER-24. Allen omits this key fact entirely.

[26] Mr. Allen and NIOSH, while admitting that MCNPX 2.7 had rendered old
numbers invalid, should not be allowed to so cavalierly state “the new values entered
into the same calculations performed previously...” since the exact, precise assumptions
and input parameters used previously (when was that, exactly?) with MCNPX have never
been described fully by either NIOSH or SC&A for the TBD-6000 WG or the full Board.

The gamma dose estimate for the first two time periods was agreed to during a working group meeting
held on 2/21/2013. [McKeel 27] These estimates were based on radium radiography and differ only by
the maximum dose prescribed by the triangular distribution. Since the radium sources would not produce
any neutron or beta radiation, the neutron and non-penetrating dose estimates are zero. [McKeel 28}
There is, however, a significant non-penetrating dose estimate for betatron operators. This opens the
possibility that the radium radiography dose estimate could be favorable to most workers but the betatron

-7-


aolrich://27814751070/

ATTACHMENT B

Danie! W. McKeel, Jr. MD



McKeel review of Allen GSI dose summary Aug. 2013

provide a page citation. Of course uranium contamination was present year round.
Uranium “dust” doesn’t all evaporate and U-238 has a radioactive half life of 4.85 million
years!

A NIOSH white paper dated April 2013 included an estimate of intakes at GSI. [McKeel 12] The same
estimate is reproduced here but the inhalation intakes from handling uranium metal were increased by a
factor of 5. [McKeel 13] The increase is due to assuming intakes occurred for 100% of the uranium
working time rather than 20%. The revised estimate is provided in Table 1 below. The inhalation intake
from resuspended material and from ingestion remains the same. [McKeel 14].

[12] What specific pages of the 6/20/13 TBD-6000 WG transcript discussed GS!
intakes? Mr. Allen needs to provide more specific citations to buttress his statements.

[13] Ingestion dose (last column at far right of Table 1): what method was used
and where is this cited? Also, ingestion is a fraction of intake inhalation, which varies, so
how is it that ingestion (dpm/day) remains constant to 2 decimal places over 14 years?
Such a supposition lacks face validity and is not scientifically plausible or defensible.

[14] The first row of data in Table 1 starts 10/4/1952. The TBD-6000 WG did not on

6/20/13, and has not ever, discussed, proposed or agreed upon either external or internai

intake or ingestion doses for the 1952 4th quarter extended covered period at GSI. Zero
monitoring data or source amount data on this 1952 GSI operational period is available

except for two brief operational monthly reports plus FUSRAP report IL.28-5 that Dan
McKeel provided to the Board and WG including NIOSH for November-1952, and an AEC
October 1952 report NIOSH provided to DOL, but has never released to the TBD-6000 WG
or to McKeel or in a white paper. 1952 uranium 1952 R&D operations took place at the
Old Betatron facility at GSI and involved MCW-AEC research and development on
uranium billets to improve radiographic image quality. A lead shield manufactured at
MCW and used at GSI was employed for the R&D NDT work on AEC/MCW billet sections.
The effect of a lead shield on 1952 external Betatron doses has not been
determined by NIOSH. This is brand new data never before presented to the Board/WG.

[15] Column 4 of Table 1 ignores the Adley 1952 data on rail road car unloading of
uranium at the Hanford Melt plant that McKeel believes is highly pertinent at GSI. McKeel
stated his findings in an Adley review white paper submitted to the TBD-6000 WG and full
Board on 6/7/13. The WG, Board and NIOSH have thus far ignored this McKee! paper
except to briefly acknowledge the MCW uranium might have arrived by rail at GSI. The
former GSI worker testimony in ATTACHMENT A clearly shows that some MCW uranium
ingots arrived at the Old Betatron building in trucks on palettes in groups of 12 or so

_ ingots. Other uranium ingots were apparently shipped to GSI from MCW (Destrehan
Street and Weldon Spring Uranium Division) plants by rail. The Adley paper indicates
that far higher Ur-238 inhalation intake doses should have been assigned to GSI workers
who unloaded the MCW uranium from rail road cars. Dave Allen has ignored this
discussion by the TBD-6000 work group and has used far less claimant favorable dose
estimates in the current paper. Mr. Allen and NIOSH need to explicitly justify why the
intake data they use is more applicable to GSI] compared to the more claimant favorable
Adley 1952 intake data. Or, they need to state clearly why Adley 1952 is not more
compelling surrogate data to use at GSI.


McKeel review of Allen GSI dose summary Aug. 2013

thicknesses of solid water slabs, using a 6 MeV photon beam and a square field size of 20
cm x 20 cm. The resulting relationship between the EPID response and the MC simulated
dose is markedly linear. This signal to dose EPID calibration was used as a dosimetric toot
to perform the validation of the MLC linear accelerator MCNP model. Simulation results
and measurements agreed within 2% of dose difference. The methodology described in
this paper potentially offers an optimal verification of dose received by patients under
complex multi-field conformal or intensity-modulated radiation therapy (IMRT).

+ PMIO: 23367244 [PubMed * indexed for MEDLINE] (REF [3] and [4] emphases added)

Dan McKeel white papers mentioned in this report (from NIOSH Docket 140 GSI):

[1] Docket 140 citation: Submission from Danie! W. McKeel, Jr., M.D., Analysis of the Adley et.
al. 1952 Hanford Melt Plant Technical Report_(June 7, 2013)_ PDF 782 KB (23 pages)

[2] This paper addresses McKee! suggested goals and the discussion of the 4/26/13TBD-6000
WG meeting on OTIB-70 and other dosimetry matters as they apply to the GSI AWE site.

+ Docket 140 citation: Submission from Daniel W. McKeel, Jr., M.D., "Goals for the TBD-6000
Work Group"_(June 21, 2013)_ PDF 1 MB (17 pages). The discussion of TIB-70 and GSI
follows the discussion of proposed work group goals, page 2 ff of 17.

el TRD-6G30 WO 4.26.)2 transcript: OYig-d70 &@ Uther Dosimeiry

TBD-6000 GSE WORK GROUP MEETING ANALYSIS:
Selected Parts of the 4/26/13 Meeting Transcript

by
Daniel W. MekKeel, Jr-, M.0.,
GST S8C-d0i05 co-petitioner
(June 14, 20153

[3] Docket 140 citation: Submission from Daniel W. McKeel, Jr., M.D., "A Review of AEC Report
NYO-4699: Accelerator (Including Betatron) Stray Radiation Measurements and Film Badge
Data at 23 Sites"_(August 19, 2013)_ PDF 431 KB (19 pages)

ATTACHMENT A pages 15-19 and ATTACHMENT B -- See page 20

Respectfully submitted,

Bes fl

fe i 4
Daniel W. McKeel, Jr., M.D. 8.30.13
GSI SEC-00105 co-petitioner



ATTACHMENT A-2,
Hello Ed, ied ve

Your answers are indeed all very helpful and much appreciated. The GSI record is now much clearer on this
particular subject. It seems that 3 the only person alive, who we have interviewed, that actually
performed the GS! Betatron shots on MCW uranium. Perhaps we can persuade him to clarify whether or not
he shot both Uranium slabs (in his existing affidavits) and ingots, or just "Betatron slices," as they are
referred to ina 1957 MCW official document. | have obtained an index of the MCW records that DOE now
holds at Oak Ridge, and hope more information from the Mallinckrodt side will emerge about the GSI
Betatron NDT uranium inspection program 1952-1966.

Most sincerely with deep gratitude for all your assistance,
--DanMcKeel 7/17/13 Wed.

In a message dated 7/16/13 4:57:42 PM, : writes:

Gentlemen: | doubt that there is much that | can add to what we already know about the above subject
but | will try to answer each question as best as | can.

3., | personally saw three (3) trucks leaving the Old betatron. We were on a 4 week swing schedule
where we would work 4 weeks of day shift (7-3) then 4 weeks of afternoons (3-11) and then 4 weeks of
midnights (11 p.m.-7 a.m.) Each time that | saw them | was coming to work on the day shift and |
witnessed the trucks leaving the old betatron. Probably about 6:50 a.m.

4. There were probably 12 ingot on each truck. Seems to me that there were three separate groups of
4 ingot each. All were loaded forward against the bulkhead of the flat bed, open staked truck which
would indicate three pallets of 4 each ingot.

-—-|-5.-The-trucks-were-not Mallinekrodt-—They-were-old,-rather-beat-up trucks;-painted-a-dark-green:-I-don't——~ --—
know why but the name "Metro hauling" seems to stick in my mind.

6. | never saw them come in but | know that they were now in house at 3 p.m. on Friday. This would
indicate to me that they came in on early Saturday mornings and always returned on Mondays. | never
saw them being held longer that that.

7. It is possible but don't know for sure.

8. Never saw them in the New Betatron.

9. No.

10. None, { was not a radiographer. | was a Foreman and film interpreter.

11. All were done in the Old Betatron.

ibout:blank Page 1 of 3


McKeel review of Alien GSI dose summary Aug. 2013

episodes of handling rather than one each direction. [McKeel 6} It should however be noted that it is
unlikely this occurred in

Allen Page 2 of 6

one area. More likely, the uranium would be moved some distance with each conveyance before being
transferred to another conveyance and airborne activity would thus not accumulate in a single area.

McKeel 7] Lastly, it possible that while the uranium is being moved on a conveyance, additional
airborne activity could be produced by vibrations. Again however, this would not occur in a single area
but rather all along the path. [McKeel 8

[5] Pure speculation: why would uranium handling in Betatron facility be more
efficient? Such speculation must be justified. This is not intuitively true. Speculation is
not good science.

[6] It is 100% certain that multiple episodes of handling uranium occurred: unload
from truck or RR car, carry with forklift to scale, weigh, reload on RR car with crane, etc.

[7] MCW uranium was transported over the same path multiple times fat GSI or 13
years, allowing for contamination to build up successively all atong the transport path.
Fallacious reasoning is used here by Allen.

[8] Same argument as [8], successive trips generate buildup all along the
transport path.

With these uncertainties in mind, it was agreed during the June 20th 2013 working group meeting that
assuming airborne activity was created during 100% of the uranium working time would be a bounding
estimate. [McKeel 9] With this assumption in place, it becomes the bounding source of internal exposure
for everyone on site. [McKeel 10] Resuspension from contamination was accounted for separately and
assumed to be present year round regardless of whether uranium was being worked with or not. [{McKeel

1 ae

[9] The 6/20/13 TBD-6000 WG transcript is 202 pages long. Mr. Allen needs to cite
the specific pages where this agreement was reached at the stated meeting for, as he
puts it, this overarching “assumption” about GSI intakes. And what period of time 1952
through 1993 (the correct end point of the GSI residual period as being 12/31/1992 is
being challenged) did this bounding intake of uranium occur?

[10] Extrapolating a bounding dose for uranium intake based on Betatron
radiographers and transport workers for “everyone in the plant” dose not meet the
“sufficient accuracy” test for dose reconstructions that are addressed by Appendix BB.
Also, the SEC Issues work group is currently assisting NIOSH in providing a sound
definition of sufficient accuracy for the first time. The author believes this fact is
deptorable for NIOSH and the Board to wait 12 years into the EEQICPA program to
address this central issue. And as an outside observer, the SEC issues WG and NIOSH
have barely constructed an outline of a definition after meeting twice about the subject of
sufficient accuracy. .

{11] What does the phrase “resuspension from contamination was accounted for
separately and assumed to be present year round...” mean? Mr. Allen, again, needs to

-2-


McKeel review of Allen GSI dose summary Aug. 2013

Daniel W. McKeel, Jr., M.D. White Paper:
“Critique of David Allen DCAS August 2013 GSI white paper
“Summary Dose Estimates for GS!”

-- 8/30/13 --
Allen Page 1 of 6

Background

During the meeting of the TBD-6000 Work Group, held June 20, 2013, the Work Group requested that
NIOSH revise its internal dose estimate for General Steel Industries (GSI), as well as provide a summary
of the dose estimates to be used in revising Appendix BB as they now stand. This white paper is intended
to address both requests.

Uranium Intake Estimate

Following discussions during the Work Group meeting on June 20, 2013, it was decided that the uranium
intake estimate for GSI would assume that airborne activity at the 95m percentile concentration was
inhaled for a time equal to the full uranium working time. Previously, the NIOSH estimate assumed
exposure only for the 20% of the time the betatron operators were in the shooting area, since that is where
the uranium was handled. Questions arose about the exposure incurred by other workers who transported
the uranium metal to the betatron building. This question is explored here.

Based on worker input [McKeel 1], x-ray shots of uranium took 60 minutes [McKeel 2} each with 15
minutes between them. Furthermore, it was reported that 4 shots were taken on each piece of uranium.
This implies the uranium was being moved only about 5% of the time the uranium was in the building (15
minutes out of 300 minutes). [McKeel 3] Since the uranium had to be positioned in the betatron building
and not just moved, it may be reasonable to think that the manipulation of the uranium in the betatron
building took more time than moving the same uranium to and from the building, That would imply the
time involved in moving uranium around the site would be less than 5% of the time it was in the betatron
building. [McKeel 4).

[1] Allen needs to cite specific transcript pages: what worker is being quoted?

{2] ‘recently testified to Dan McKeel and that each
uranium shot, after being set up, required only 40 minutes. His complete recent
testimony is ATTACHMENT A. His testimony complements that of and

[3] That MCW uranium was in the Betatron building only 300 minutes is pure 160%
speculation, made up. Not true, not verified by any worker testimony.

[4] The GS! uranium transport path by rail was very long and not thoroughly
established as to actual length in yards or in transit time in minutes. Again 5% is pure
conjecture, scientifically indefensible, certainly too short a time allocated.

» Summary: these ‘facts” are either inaccurate or fabricated; all are scientifically
indefensible.

However, there are several possibilities that could change that assumption. First, it is possible the
handling inside the betatron building was more efficient than outside even if inside involved proper}
placement and not just movement. [McKeel 5] Second, it is possible the uranium was moved from
conveyance to conveyance within the site (fork truck, rail car, crane, etc.) thus representing multiple

-1-


McKeel review of Allen GSI dose summary Aug. 2013

(f) Doses assigned to administrative and all other personnel must include neutron and beta skin
doses. NYO-4699(Suppl.1) 1957. Betatron and film badge measured data should be the basis
for these numbers.

({g) This paper does not comply with OCAS-IG-003 in ignoring the uranium, Old Betatron, 250
KVP x-ray units and Ir-192 sources in use during the radium era at GSI (1953-1962).

(h) NIOSH needs to bound Betatron photon, neutron and beta skin dose during the 10/1952
through 12/52 extended covered period, when GSI was conducting R&D NDT image
improvement research with AEC uranium billet sections from MCW. SC&A needs to review this
work. The new bounding data needs to be assessed for sufficient accuracy by the WG/SC8A..

(i) Photon and neutron external doses need to be calculated for persons working and traversing
the area between to Old and New Betatrons and who were exposed to the two GSI Ra-226
sources 1952-1955 before the 6 Bidg. radiography room was built,

(j) ATTACHMENT A contains highly pertinent GSI Betatron multi-operator detailed descriptions
of the AEC supported MCW NDT radiography work performed at GSI 10/1952 through June
1966. One operator describes working with Betatron slices, whereas the other workers describe
Betatron work on uranium ingots. Other details of the NDT scenarios vary among the workers
as well. The resulting data as to time it took to shoot uranium with the Old and New Betatrons
should thus use the most claimant favorable. The testimony supports the idea that grazing
corner shots primarily sharply delineated the pure uranium, Mg-Fluoride slag/Ur ingot interface.

(k) ATTACHMENT B is historical February 2007 correspondence between GS! SEC-00105 co-
petitioner Dan McKeel and yand of the RS Landauer company that
supplied GSI program #2084 photon film badges to 89 GSI Betatron and isotope radiographers
during a minor part of the covered period November 1963 through June 30, 1966. Landauer’s
badge monitoring program extended to the end of the active castings activities at GSI in 1973.
Ms. with Mr. assistance, outlines Landauer's information on “the reporting
level and radiation exposure limits” in force during the #2084 GSI film badge program.

McKeel References

1. McLaughlin Jr. JE, O'Brien K, Solon LR, Zua AV, Lowder WM, Biatz H. “Stray radiation
at particle accelerator sites,” NYO-4699(Supplement 1), Health and Safety Laboratory AEC and
Division of Research AEC, 86 pages, April 1, 1957. URL link:
www.osti.gov/bridge/serviets/purl/4306039-Gel6fn/

2. Solon LR, McLaughlin JE, Blatz H. “Stray radiation measurements at particle accelerator
sites,” Report NYO-4699, June 1, 1956, 62 pages. URL link: (furnished to DWM Jr by James
Neton of NIOSH): www.osti.gov/bridge/servlets/purl/4361972-MVSO9P/

3. Leone J, Furler M, Oakley M, Caracappa P, Wang B, Xu XG. Dose mapping using
MCNP5 mesh tallies. Health Phys. 2005 Feb;88(2 Suppl):S31-3
Source

Rensselaer Polytechnic institute, Troy, NY 12180, USA.

Abstract
» Rensselaer Polytechnic Institute has a 69.6 GBq (1.88 Ci) (137)Cs source that is used for

-12-


ATTACHMENT A-1

GSI_affidavits_2013.fp5

NUM

TIME
LASTNAME
FIRS THAME
START_¥R
END_YR
JOB
MIG_DATE
KEY_WORDS

02
MCW UR Ingots were x-rayed in the GSI Betatrons

Betatron operator
7/7/2006

pp 15-17; 31 .

Probably about 1965, they sent some slices with a waxy coating on it for us
to x-ray on the midnight shift. They came into the old Betatron building
on flatcars. A couple of rights later they sent some small ingots. We had
to use three different films to shoot them because of the exposure and the

- variation of thickness. We divided the slices up into four shots and backed

it up with lead, and pointed the Betatron straight down. It took a lot longer
than a normal piece of metal that you were shooting. There were four

“7 = exposures-and each-ex posure-took-a-couple-of hours (7/7/06-Meeting ———— - --

Transcript, pp. 15-17). There was some type of identification on them
that we wrote from that ingot onto the shot sheet. They were x-rayed in
both the new and old Betatron buildings. I operated back and forth, but
most of mine was in the old Betatron building.

DMLIBRARY 1-#259452-v1-CSI_Affid